Consultation response: MCS Competency Framework
24th August 2022
Earlier this year, MCS consulted on the competency requirements associated with achieving and maintaining certification. This consultation closed on the 11th April 2022, having received responses from a wide range of organisations.
MCS would like to thank those who provided responses to the consultation. This consultation process has supported the implementation of the new MCS Competency Framework, to be defined through:
(1) A rewrite of MCS 025 as the MCS Competency Standard.
(2) The adoption of a new approach to the approval of training programmes assessed to be in alignment with the industry’s competency criteria for the installation of a given technology, and their delivery.
We expect to publish our new Competency Framework in September 2022.
Overview: revision of MCS 025 – The Competency Standard
Responses to the consultation broadly agreed with the proposal to streamline the previous range of ‘company roles’ described in MCS 025 to the two key roles of ‘Nominee’ and ‘Nominated Technical Person’ (NTP).
- Feedback suggested that the roles of Nominee and NTP would benefit from greater clarity, with a minority of respondents suggesting a change to the role titles. The upcoming revision to MCS 025 will now clarify the purpose of these two roles in achieving and maintaining MCS certification. As the roles are now generally understood by the sector, MCS intends to retain them as part of its competency framework.
- Responses requested that an NTP be able to evidence competency in more ways than had been listed in the proposed MCS 025 clause 3.2.2. This clause will now also refer to attaining personal certifications aligned to ISO 17024.
- The majority of respondents suggested that a contractor must notify their certification body (CB) of a change in Nominee or NTP within a shorter timeframe than was described in the proposed revisions to MCS 025. The upcoming revision to MCS 025 will require contractors to notify their CB of a change in Nominee or NTP within 30 days. Plus, given the importance of the NTP role, contractors will not be able to complete any installations until a replacement NTP is assigned.
Determining MCS competency requirements and approved training
Here is a summary of responses related to the basis of MCS competency requirements and an associated list of approved training that matches these competency requirements:
- Respondents welcomed the new MCS competency framework described in the consultation, including aligning MCS competency requirements to the Minimum Technical Competencies (MTCs) to create a consistent set of competency requirements across the industry.
- Respondents requested clarity on the approval process for new training provisions. This is provided in the response to Question 4 in the final section of this summary.
- Some respondents questioned the validity of qualifications ‘approved’ in the past and whether MCS would honour these qualifications. MCS will continue to recognise existing training provision, until such a time that retraining and/or reassessment is considered necessary e.g., if there is a significant change to the sector’s technological and/or working practices.
- Respondents requested clarity on the competencies necessary for heat pump system design, in line with MIS 3005 The Heat Pump Design Standard. MCS will publish separate heat pump design competencies and seek feedback from the sector, providing a basis for MCS approval of ‘design-only’ heat pump courses, given that the MTCs do not provide a distinct set of design-based competencies.
In-depth overview of the consultation responses
Here is a summary of feedback to the questions asked in the consultation. These responses have been used to support the design of the new MCS Competency Framework.
QUESTION 1: Do you agree with the proposal for reassessment of a Nominated Technical Person’s competency every five years?
In general, respondents supported the sector’s need to maintain minimum levels of competency. Some respondents described a need for continuing professional development (CPD), outside of MCS competency requirements, to improve skill levels more generally across the sector’s workforce.
The majority of respondents were in favour of reassessment every five years. However, feedback was more nuanced than a simple ‘yes’ or ‘no’ to Question 1:
- A minority of respondents questioned the need for reassessment fixed to a rigid timescale. These respondents suggested if the associated installation standards have not changed significantly in the intervening period, and the NTP has been active in the sector during that time, then reassessment may not be necessary.
- Respondents also described the potential for significant market and technological changes in future years, which might require the need for further training and reassessment more frequently than every five years.
- A further response suggested that evidence of the need for retraining and/or reassessment would need to be presented to the market to justify the cost of reassessment.
Based on the majority of consultation responses, the new MCS Competency Framework will be based on the following expectations:
- an NTP can demonstrate up-to-date knowledge and an understanding of current Standards
- an NTP can identify any significant technological or market changes that have occurred since their first assessment or previous reassessment.
The ‘reassessment requirement’ within the new MCS Competency Framework will act as a basis for the provision of reassessments, appropriate to each technology within scope for MCS.
- NTPs will be required to complete an appropriate reassessment every five years. This approach will align MCS with the requirements of other industry sectors for the demonstration of competency.
- With the support of the MCS Standards community, MCS will continually review the minimum scope and requirement for reassessment for each technology, publishing revisions to these requirements when changes are necessary.
- The scope and requirement for reassessment will incorporate significant technological and/or working practice changes as they occur, in addition to a reassessment of core competencies for each technology. It is unlikely that reassessment will need to mirror the original/initial assessment or require the NTP to retake their original training.
- MCS accepts that outside of MCS Competency Framework requirements, individual training qualifications and personal certifications may mandate reassessment at different times.
1.1 MCS will adopt a five-year reassessment policy. The requirement for reassessment will be described in the new version of MCS 025, and the minimum criteria for each technology type will be published on the MCS website.
1.2 As a standing item for MCS Technical Working Groups, MCS will monitor whether technological and/or working practice changes necessitate a revision of both MCS competency requirements and reassessment criteria. MCS will also monitor new versions of the MTCs, which are expected to reflect the sector’s competency needs over time.
1.3 As is the current case, CBs will continue to assess an NTP’s competency. In addition, CBs will now need to check compliance with the MCS reassessment criteria by technology.
QUESTION 2: Do you agree with the proposal for a MCS contractor (certified business) needing to identify one or more Nominated Technical Person(s) (NTP) depending upon the volume and complexity of their activity?
In general, respondents were supportive of a requirement for an MCS contractor to identify the supervision requirements appropriate to their operations. The consultation response underlined the need for MCS contactors to have technically competent and qualified employees, despite whether these individuals have been identified as the NTP(s) in relation to a contractor’s MCS certification.
There was less support for a prescriptive definition of what the supervision requirements should be. Several responders suggested that the contractor should determine this for themselves and be able to evidence to their CB the calculations used to determine their supervisor-to-operative ratios, and how supervision is maintained to ensure the quality of work. One respondent referred to the recent split in the MCS Heat Pump Standard between Design and Installation as an example of distinct activities that would likely require different levels of supervision.
2.1 MCS will adapt the proposed clause 3.2.4 in MCS 025, placing the onus on the MCS contractor to evidence an appropriate supervision model. If requested, the contractor will need to provide evidence of the calculations used to determine their supervisory model and how supervision is recorded and monitored.
QUESTION 3: MCS proposes to remove the ‘Experienced Worker Route’ as an option for assessing individual competency.
Respondents recognised the importance of worker experience. At a time when the sector looks to grow, some expressed concern that removing a route into the sector – in addition to the achievement of qualifications and personal certification – risks limiting a future workforce.
In reviewing the range of responses provided to this question, MCS believes a distinction needs to be made between the need for experienced workers, who we wish to attract to the sector, and the operation of the Experienced Worker Route (EWR) under MCS.
- The EWR was intended to allow individuals with qualifications other than those approved, or with no formal qualifications or personal certifications, to provide evidence of relevant experience covering the competency requirements as assessed by a CB. Based on the responses, especially those received from CBs, the EWR has failed in practice to offer an achievable and robust route for the assessment of competency under MCS.
- Several respondents highlighted the need for the sector to attract ‘experienced workers’, especially for the installation of low-carbon heating technologies, such as heat pumps. A case was raised to recognise an individual’s ‘prior learning’. For example, MCS notes that the current heat pump installation and maintenance short courses prescribe a range of requirements that someone with experience in a parallel sector can use to participate in this training.
MCS believes that recognising prior learning and experience as a requirement for what some refer to as ‘upskilling courses’ will allow an ‘experienced worker’ to enter the sector. This is on the basis that MCS intends to recognise the achievement of short course qualifications or personal certifications as evidence of an NTP’s competency.
A minority of respondents were concerned about an appropriate transition period for those already in the sector without approved qualifications or personal certifications.
3.1 MCS will remove the Experienced Worker Route from the new MCS Competency Framework as a way of assessing the competency of an individual.
3.2 MCS will list ‘approved’ training courses that cover the published competencies, including the range of current short courses for the installation of MCS certified technologies. These include short courses for the installation and maintenance of heat pumps that require learners to have a minimum NVQ Level 2/3 qualification in plumbing or conventional heating engineering or a demonstrable number of years of relevant experience.
3.3 MCS will retire the ‘Competency Guidance’ document from the MCS Standards Library.
3.4 After the MCS Competency Framework is published, and from the 1st April 2023, all new NTPs for existing MCS certified contractors, or NTPs associated with new applications for MCS certification, will be required to demonstrate their competency aligned to the new MCS Competency Framework i.e. hold one of the approved qualifications or personal certifications, or in the future have taken an MCS approved competency assessment. For the avoidance of doubt, existing NTP(s) working for an existing MCS contractor certified before 1st April 2023 will benefit from so-called ‘grandfather rights’, meaning that their status as the contractor’s NTP is unaffected by the publication of this revision to MCS 025.
QUESTION 4: What should MCS consider when approving new training provision that has been assessed as meeting the scheme’s competency requirements?
A majority of respondents identified the need for training provision to be mapped against a common set of competency requirements. MCS intends to refer to the MTCs, versus developing a further set of competency requirements for the sector.
For MCS to recognise independent assessments of competency or non-regulated training provision (for example, an organisation’s own in-house training academy programme) respondents suggested that these would need to demonstrate the same alignment to the MTCs and robustness of assessment as provided by formal qualifications and personal certifications. If MCS did not operate in this way, the feedback suggested that this would risk devaluing formal qualifications and certifications in favour of potentially less rigorous non-regulated training programmes.
Given that national training provision, including apprenticeships, already has effective governance in place, some respondents stated that MCS should look to recognise it, rather than approve.
4.1 MCS will recognise existing formal qualifications and personal certifications, including those that lead to Ofqual accredited qualifications or UKAS accredited personal certifications. As stated in the consultation, current MCS approved training provision of this nature will be listed on the MCS website, offering clarity on the training available for those new to the sector.
4.2 In the interest of increasing the sector’s workforce and ensuring the quality of available training routes, MCS will pilot a relationship with an independent skills training assessment organisation. This pilot will:
- Enable the assessment of new provision, ensuring alignment to the MTCs
- Allow for the assessment of training delivery; but to avoid duplication of work for training centres, accept existing certification body or awarding organisation centre approval as a proxy.
4.3 In the interim, MCS will continue to recognise a range of existing courses that can establish the competency of individuals. The MCS Competency Framework will refer to a list of these courses and qualifications, which will be hosted in a dedicated section on the MCS website.
4.4 MCS competency requirements will be based on the MTCs. Consequently, MCS will disband its own Competency Working Group. If the MTCs are found not to cover all MCS design and installation requirements, MCS will engage its Technical Working Groups and facilitate broad industry consultations to determine scheme specific competency requirements.
We expect to publish the new MCS Competency Framework, which includes the revised MCS 025 Competency Standard, in September 2022.